BSA Compliance Series: Job-Specific BSA for Deposit Operations: SAR Monitoring, 314(a) Requests & CIP

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Deposit operations staff must have effective, ongoing training to support several critical BSA requirements. This webinar will focus on three areas that are focal points of transaction testing sections of the BSA exam process. Real-life examples of suspicious activities detected by deposit operations staff will be included, along with practical tips for processing and protecting the confidentiality of time-sensitive 314(a) requests. In addition, examiners have been closely monitoring CIP compliance and many financial institutions have been surprised by the findings. This session will include examples of CIP deficiencies in recent BSA enforcement actions and provide additional monitoring tools for deposit operations staff.


  • When an account is opened, what does the frontline need to know regarding customer due diligence (CDD), enhanced due diligence (EDD), and beneficial ownership?
  • Risk assessment best practices for CDD and EDD in 2017 – and 2018 changes
  • Tips for monitoring an effective CIP, including case studies
  • Recent enforcement actions on failure to identify, monitor, and report suspicious activity
  • Tips for deposit operations staff to avoid five violation areas
  • Seven steps that should be included in 314(a) procedures
    • Designation of a contact person
    • Notification process
    • Record search
    • Review of potential matches – how are positive matches reported to FinCEN?
    • What types of escalation are required for potential matches and investigation?
    • Confidentiality requirements
    • Best practices for documentation and record retention


  • SAR checklist based on BSA exam procedures and the risk assessment process
  • Sample BSA responsibility matrix, including SAR monitoring, 314(a) requests, and CIP
  • Template for sample CDD policy for new beneficial ownership requirements and BSA fifth pillar
  • Compliance review checklist for 314(a) procedures
  • Employee training log
  • Quiz you can administer to measure staff learning and a separate answer key


This informative session is designed for BSA officers and staff, deposit operations staff, loan operations personnel, loan officers, branch personnel, risk managers, compliance officers, new account staff, and auditors.

ABOUT THE PRESENTER – Susan Costonis, Compliance Consulting and Training for FIs

Susan Costonis is a compliance consultant and trainer who began her career in 1978. She specializes in compliance management along with deposit and lending regulatory training. Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.

Originally recorded on August 15, 2017.

Recorded webinar is available until February 28, 2018.

Free Digital Copy included with purchase to download and view beyond link expiration date.

Price includes sales tax.